Narbaitz v. Commissioner of Social Security

Filing 15

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 12/27/2018 for defendant to file a responsive brief, with all other dates extended accordingly. Order signed by Magistrate Judge Erica P. Grosjean on 11/6/2018. (Rooney, M)

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MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, CA 94105-1545
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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CAROL ANN NARBAITZ,

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Plaintiff,
v.

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NANCY A. BERRYHILL, Acting
Commissioner of Social Security,
Defendant.

) Case No. 1:18-cv-00285-EPG
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) STIPULATION & ORDER FOR
) EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties through their respective

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counsel of record, with the Court’s approval, that Defendant shall have a 45-day extension of time,

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from November 12, 2018 to December 27, 2018, to respond to Plaintiff’s Motion for Summary

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Judgment. All other dates in the Court’s Scheduling Order shall be extended accordingly.

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This is Defendant’s first request for an extension of time. Defendant respectfully submits

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that good cause exists for the requested extension because Defendant’s counsel requires additional

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time to review the record, to evaluate the issues raised in Plaintiff’s Motion for Summary

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Judgment, to determine whether options exist for settlement, to prepare Defendant’s response to

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Plaintiff’s Motion if settlement is not possible, and to accommodate other workload demands.

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Plaintiff does not oppose Defendant’s request for an extension of time.

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Respectfully submitted,

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Dated: November 6, 2018

CERNEY KREUZE & LOTT, LLP

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By: /s/ Shellie Lott*
SHELLIE LOTT
Attorneys for Plaintiff
[*As authorized by e-mail on Nov. 5, 2018]

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Dated: November 6, 2018

MCGREGOR W. SCOTT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration

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By: /s/ Margaret Branick-Abilla
MARGARET BRANICK-ABILLA
Special Assistant United States Attorney
Attorneys for Defendant

ORDER

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Pursuant to the above stipulation of the parties, Defendant shall have a 45-day extension of
time, to December 27, 2018, to file a responsive brief. All other dates in the Court’s Scheduling
Order shall be extended accordingly.

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IT IS SO ORDERED.
Dated:

November 6, 2018

/s/
UNITED STATES MAGISTRATE JUDGE